Ruber AML/KYC/CTF Policy

KYC (Know Your Customer) means procedures aimed at identifying and verifying the identity of Users.

KYT (Know Your Transaction) means procedures for analysing cryptocurrency addresses and transactions to identify sources of funds, connections to high-risk or prohibited activity, and other risk factors.

AML/CFT (Anti-Money Laundering and Combating the Financing of Terrorism) means procedures aimed at preventing and detecting the laundering of proceeds of crime and the financing of terrorism.

Proof of Funds (PoF) means providing documents or information confirming the availability and lawful nature of the User’s funds.

Source of Funds (SoF) means providing information and documents about the origin of funds used in a specific operation in order to confirm their lawful nature.

High-risk transaction means an operation whose characteristics indicate an elevated risk of money laundering, terrorist financing, fraud, sanctions violations, or other unlawful activity. Such characteristics may include unusual amounts or behaviour, funds originating from high-risk sources or jurisdictions, links to sanctions, and other suspicious factors.

High-risk address labels are assessments (labels/tags) assigned to cryptocurrency addresses by AML analytics systems when links to suspicious or prohibited activity are identified, including, without limitation, darknet marketplaces, mixers, fraud (Scam), stolen funds (Stolen Coins), ransomware, sanctions restrictions, terrorist financing, and other elevated-risk categories.

Dark Market means an online platform associated with the sale of illegal goods or services, including narcotics, weapons, stolen personal data, and other prohibited items.

Sanctions means restrictions or prohibitions imposed by international organisations or authorised government bodies with respect to states, territories, legal entities, or individuals.

Stolen Coins means cryptoassets obtained through theft, fraud, or another unlawful act and/or included in sanctions lists or investigation materials.

Scam means a deceptive scheme that results in the loss of money or other assets, including fraudulent investment projects, pyramid schemes, phishing, and other forms of manipulation.

2.1. The User must complete identity verification at the request of the Service and in accordance with its requirements. The Service may request additional information and documents to verify identity, a particular operation, the source of funds, or the recipient of funds for the purpose of complying with applicable law and this Policy.

Verification may be performed with respect to both the User and the Recipient of funds under an Order, in particular when cash is disbursed, funds are transferred to a third party, or indicators of elevated AML/CFT risk are present. The Service may engage specialised third-party KYC services to verify the authenticity of information. Refusal to provide requested information or documents may result in suspension of the operation, refusal to carry it out, or termination of services.

2.2. The verification procedure may include, without limitation, the provision of:

• an identity document: a domestic passport, international passport, ID card, driving licence, or another acceptable document;
• a photograph or selfie with the document to confirm identity;
• a video recording, video call, or liveness and facial-match check;
• a telephone number, email address, residential address, and other information necessary for verification;
• information and documents under the Proof of Funds (PoF) procedure;
• information and documents under the Source of Funds (SoF) procedure;
• documents and information about the Recipient of funds if necessary to review the Order.

The requested information is used to comply with AML/KYC/CFT requirements, assess risk, and confirm the lawful nature of the operation.

3.1. The Service applies a system for identifying high-risk transactions and other unlawful activity, taking into account the risks of money laundering, terrorist financing, fraud, and sanctions violations.

To comply with AML/CFT requirements, the Service uses a combination of external analytics tools and internal monitoring procedures to assess risks associated with transactions, cryptocurrency addresses, and User activity.

The assessment follows a risk-based approach and considers a combination of factors rather than being limited to indicators from external analytics tools. These factors include, without limitation, geographic risks, sanctioned addresses and services, the use of obfuscation methods including mixers and bridges, an unusual operation pattern, inconsistencies between User information and the circumstances of the Order, and other indicators of elevated risk.

To prevent circumvention of control mechanisms, the Service does not disclose thresholds, internal rules, algorithms, or other risk-assessment criteria. This information is confidential.

The Service may suspend operations and temporarily hold funds until the necessary information is provided and the review is completed.

To reduce the risk of an operation being suspended, the Service recommends that Users:

• perform an independent AML check in advance or provide the address or transaction identifier to a Ruber operator for a preliminary assessment before carrying out the exchange operation;
• regularly review the current version of this Policy;
• use recognised specialised services to conduct AML checks;
• not send funds from third-party addresses unless this has been agreed with an operator in advance.

A low AML risk level does not guarantee acceptance of funds or successful completion of an exchange operation; it only indicates a lower level of identified risk. A final assessment is possible after the funds have actually arrived and the transaction has been analysed. Even when no high-risk labels are present, the operation may be reviewed further for compliance with the Service’s internal requirements.

3.2. The Service monitors User transactions to identify anomalous or suspicious operations. For these purposes, the Service uses GetBlock analytics solutions and/or other reputable analytics resources at its discretion, separately or in combination.

Under this Policy, an operation is considered suspicious if it:

• is connected with funds obtained through unlawful activity or is carried out to conceal or disguise the origin of such funds;
• is intended to evade lawful obligations relating to record-keeping, identification, or disclosure of information;
• has no apparent lawful or economically justified purpose;
• facilitates criminal activity, including fraud, money laundering, terrorist financing, corruption, extortion, or sanctions violations;
• is connected with darknet marketplaces, mixers, stolen assets, fraudulent services, prohibited goods, or other elevated-risk categories;
• does not correspond to information stated by the User or to the usual pattern of their operations.

3.3. If the AML risk level set by the Service is exceeded or high-risk funds are identified, including Dark Market, Sanctions, Stolen Coins, Scam, and other categories, the Service may:

• suspend the operation or temporarily hold funds until the review, full identity verification, and review of financial information are completed;
• request a photograph or video recording with an identity document;
• request screenshots or a video recording from the cryptocurrency wallet account or other platform from which the funds were sent;
• request the transaction identifier (TXID), statements, receipts, agreements, and other materials relating to the operation;
• request documents and information about the Recipient of funds under the Order;
• request additional materials under PoF/SoF procedures;
• refuse to transfer funds to a third party’s account or address;
• terminate or restrict services to the User in the cases provided for by this Policy.

If the User does not provide the requested information or does not respond within 3 (three) months, the funds may remain temporarily held until the Service’s requirements are met or lawful grounds for another decision arise.

After all necessary documents and information have been received, the standard internal review period is up to 12 (twelve) business days. This period may be extended if the review depends on a response from a bank, payment partner, analytics service, or competent authority, or requires additional investigation. The Service informs the User of a material extension through official communication channels unless such notice is prohibited by law.

Funds held in connection with sanctions restrictions or a lawful requirement of a competent authority may remain blocked until the relevant restrictions are lifted or permission for further action is received.

3.4. The Service may complete an exchange operation only after:

• the necessary identity verification of the User and, where applicable, the Recipient of funds has been performed;
• the transaction risks have been assessed, including its links to high-risk sources, sanctions, Dark Market, Stolen Coins, Scam, and other risk indicators;
• the submitted documents and information have been reviewed, including identification data, wallet information, and PoF/SoF materials if the operation is classified as high-risk;
• identified inconsistencies have been resolved and the lawful nature of the operation has been confirmed.

The Service does not provide services to persons located in or connected with the territories of the following states and regions: the Republic of Abkhazia, the Republic of South Ossetia, the Nagorno-Karabakh region, the Turkish Republic of Northern Cyprus, the Transnistrian region of the Republic of Moldova, and territories of Ukraine subject to applicable international sanctions or restrictions.

In addition, the Service does not provide services to persons included in applicable sanctions lists, including those of the United Nations, the European Union, the UK Office of Financial Sanctions Implementation (OFSI), and the US Department of the Treasury’s Office of Foreign Assets Control (OFAC), or to persons whose servicing is prohibited by applicable law or by restrictions of the Service’s payment partners.

The Service may screen Users, Recipients, and details associated with an operation against these lists and may suspend or terminate services when sanctions risk is identified.

The Service monitors transactions and User behaviour for indicators of suspicious operations. When such indicators are identified, information is referred to the responsible persons within the Service for internal review and, where required by applicable law, may be provided to competent regulatory or law-enforcement authorities.

In such cases, the Service may request additional information or documents from the User, suspend or terminate services, and temporarily hold funds until the review is completed.

The Service may refrain from disclosing to the User that a report was made, the content of the review, or other information where disclosure is prohibited by law, may impede an investigation, or may enable circumvention of control mechanisms.

For the purpose of complying with AML/KYC/CFT requirements, preventing fraud, and protecting the rights and lawful interests of the Service and its Users, the Service may temporarily suspend operations and hold funds when elevated risk, a suspicious transaction, or inconsistencies in submitted data are identified.

Such cases include, without limitation, operations connected with high-risk sources, sanctioned persons or restricted territories, Dark Market, Stolen Coins, Scam, mixers, ransomware, terrorist financing, and other indicators defined by this Policy.

An exchange operation is completed or funds are returned after successful verification, review of the submitted information and documents, and completion of the internal review. If the operation cannot be carried out, funds are returned to the originating payment details after deduction of the actual blockchain network, bank, or payment-partner fee and other direct return costs, except where a return is prohibited by applicable law, sanctions restrictions, or a requirement of a competent authority, or is technically impossible.

A return to a third party’s payment details is permitted only after additional review and at the decision of the Service. A return under an already completed Order is not possible.

All enquiries concerning suspended operations and temporarily held funds are accepted only through official communication channels listed on the Service website and from the email address or Telegram account provided by the User when creating the Order or contacting an operator. Funds may remain temporarily held until all required procedures are completed.

Documents and data provided by Users, including verification results and information about transactions and completed reviews, are retained for at least 5 (five) years after the relationship with the User ends. The retention period may be extended where required by applicable law, a request from a competent authority, the prevention of repeated fraud, dispute resolution, or protection of the Service’s lawful interests.

The Service collects, stores, and protects Users’ personal data in accordance with applicable data-protection rules, this Policy, and the Service’s Privacy Policy. To perform KYC and AML/KYT checks and fulfil an Order, data may be transferred to specialised identity-verification providers, analytics services, banks, and payment partners to the extent necessary for the relevant purpose.

Verification and transaction records are provided to competent regulatory or law-enforcement authorities only where there is a lawful basis.

The Service may amend this Policy to reflect changes in legislation, regulatory requirements, sanctions lists, technologies used, and internal procedures.

The Service may amend the Policy unilaterally without prior notice to Users. The current version is published on ruber.exchange with the date of the latest changes shown at the top of the page. Continued use of the Service after a new version is published constitutes the User’s agreement to the updated Policy.

The controlling language of this Policy is Russian. Translations into other languages are provided for convenience; in the event of any discrepancy, the Russian version applies.

For questions relating to this Policy, verification, or review of an operation, contact Ruber only through the official channels:

• website: https://ruber.exchange;
• email: support@ruber.exchange;
• Telegram bot and Mini App: https://t.me/ruberapp_bot.

Ruber is not responsible for information or payment details received by the User through unofficial accounts, websites, or other communication channels.